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On 14^th March 2023, FullCircl joined some of the UK’s leading financial crime thought leaders to share our expertise and key insights into the best practice Anti-Money Laundering (AML), compliance, and anti-fraud strategies helping financial institutions gain competitive advantage in the field of regulatory compliance and stay ahead of KYC requirements.

The highlight was the main stage panel discussion, hosted by our very own EVP Identity Solutions, Warren Russell.

Warren was joined by Stephen Frame, CCO & MLRO at Caxton, Helen McHugh, BDM at Transact Payments, and Phil Seymour, Senior Risk and Compliance Officer at Payabl. Together they discussed how financial institutions (FIs) can look to technology to ensure compliance at a time when the UK and European regulatory landscape is becoming ever-more complex.

Topics included how to balance the need for KYC compliance whilst managing customer expectations, the potentially prominent role AI might play in KYC processes, the future of compliance, and how FI’s can stay ahead of regulation.  

Here's our key takeaways from the event…

The 2024 regulatory environment

Stephen Frame identified 2024 as the busiest year he has ever known for regulatory change.  

It is certainly set to be big year for FIs. We can expect evolving requirements around AML and KYC regulatory compliance, PEPs, sanctions, and Ultimate Beneficial Ownership.  The implementations of the Economic Crime and Corporate Transparency Act, The Financial Services and Markets Act, and updates to the 6^th Anti-Money Laundering Directive and The Payments Services Regulations, as well as increased scrutiny of cryptocurrency, authorised push payments, ESG, and of course the role of artificial intelligence (AI).

In its recent plan for the year ahead, the Financial Conduct Authority (FCA) highlighted its bold strategy of far-reaching reforms aimed at reducing and preventing financial crime, improving the integrity of the financial system, and ensuring the UK remains an attractive place to invest.  As the panel pointed out, the FCA is becoming more proactive in developing regulations and informing FIs on how best to comply.

So, what does this ocean of pressure really look like for compliance professionals?

The role of compliance is changing

The panel agreed we’re moving away from compliance being a tick-box exercise, to being at the forefront of FI activities. Accordingly, there must be a shift in the FI mindset towards becoming more compliance focussed.

Traditional compliance check lists are simply not effective in such a pressurised regulatory environment. A more dynamic and proactive approach to AML and KYC compliance is required, not only to remain responsive in this fast-moving regulatory environment, but also to stay ahead of ever more sophisticated financial crimes.

The panel also pointed out that there’s no excuse for manual KYC processes in 2024. High profile failures in AML and compliance stand as testament to the risks of failing to embrace technology. Data analytics, digital identity verification, enhanced due diligence, and perpetual eKYC/eKYB now form a fundamental part of compliance best practice and effective management of financial crime risk.

Not only that, but technology is also redefining compliance by streamlining onboarding processes and enhancing customer experiences.

How should FIs need balance compliance and experience?

In addition to further integration of technology in AML and KYC checks, and more proactive approaches to risk management, a big focus for FIs in 2024 will be increased efforts to balance regulatory compliance with exceptional customer service. To this end, the panel believed that a bigger technology budget is needed if FIs are to better support developing regulations and balance this with rising customer expectations.

In addition to charting a more dynamic compliance course, FIs need to ride a wave of heightened customer expectations. AML and KYC processes must not add friction to client onboarding journeys and other key customer lifecycle touchpoints. However, for many FIs, it remains a truism that as KYC regulatory requirement makes processes more onerous, the customer experiences is detrimentally affected.  

The panel agreed that KYC and compliance cannot be an afterthought if FIs want to reduce friction.

FIs must make efforts to design compliance strategies around the user experience. Utilising advances in data and automation, such as digital identity verification, real-time PEPs and sanctions watchlist screening, adverse media data, KYC documents checks, and KYB, lessen the need for manual intervention, leaving compliance professionals free to focus on more complex tasks. Thus, successfully balancing the need to comply with current and future regulations whilst delivering superior customer experiences.

Choosing the right technology partner is therefore vital.

Why FI-Regtech collaboration is key to success

As each new regulatory change appears on the horizon, so too does a new wave of requirements and obligations FIs must contend with, in addition to staying on top of all the updates, amendments and additions to the myriad of existing regulations.

The panel therefore believed that 2024 will also be a year of strategic collaboration. FIs must seek technology partners that not only offer a great product suite, but also have the industry experience and expertise to support, guide and advise in building more proactive approaches. Simultaneously enhancing compliance, improving the customer experience, driving operational efficiency, responding to regulation, and fostering the secure financial ecosystem the FCA demands.

RegTech is no longer the new kid on the block. Instead, providers are established as invaluable collaboration partners when FIs have new regulatory goals to reach or new risk management challenges to overcome. RegTech’s are leveraging AI and Machine learning (ML) for KYC and AML purposes, with a range of tools used to verify customers’ identities, eliminate manual error, streamline and automate processes, and most importantly mitigate fraud and other financial crimes fitting a risk based approach.

But, the panel agreed that not all RegTech's are created equal. The key is finding a partner with both the technology capabilities and industry expertise needed to build an environment of compliance best practice.

Why W2 by FullCircl is a compliance game-changer in 2024

With W2 by FullCircl FI’s can onboard more customers and meet regulatory requirements with automated KYC compliance software, AML, anti-fraud, and identity verification solutions through an intuitive orchestration platform.

As part of the FullCircl group, we enable organisations to address to many of the most critical commercial and regulatory challenges, and provide the wrap-around support, training and guidance FIs need to ride the wave successfully.

Get in touch with our team to find out more.

KYB, short for Know Your Business, is a due diligence process that focuses on verifying the identity and legitimacy of business entities. Just as Know Your Customer (KYC) procedures are employed to verify the identity of individuals, KYB checks help organisations assess the authenticity and trustworthiness of other businesses.

KYB involves collecting and verifying relevant information about a business, such as its legal name, address, registration number, and ownership details. This data is then compared against reliable sources, ensuring compliance with regulatory requirements, and minimising the risk of engaging in fraudulent or illicit activities.

In today’s fast-paced and interconnected business environment, it’s essential for organisations to have a comprehensive understanding of their clients and partners. This understanding goes beyond just knowing their names and addresses. It involves delving deeper into the legitimacy and background of these businesses. This is where Know Your Business (KYB) comes into play.

The meaning of KYB checks

KYB checks involve conducting thorough investigations into the background of a business entity. These checks typically include:

• Verifying the legal status of the business by reviewing registration documents and certificates. This ensures that the business is properly registered and authorised to operate.
• Confirming the physical location of the business and cross-checking it against official records. This helps validate the legitimacy of the business’ operations.
• Validating the ownership structure of the business to identify the Ultimate Beneficial Owners (UBOs). Understanding who controls and benefits from the business is crucial for assessing its transparency and potential risks.
• Assessing the business’s financial stability and reputation in the industry. This involves analysing financial statements, credit reports, and industry evaluations to gain insights into the business’s financial health and standing.
• Screening the business against watchlists, sanctions lists, and politically exposed person (PEP) databases. This step helps identify any connections to individuals or entities involved in illegal activities or sanctions.
• By conducting these checks, organisations can gain valuable insights into the businesses they interact with, mitigating potential risks and enhancing their overall security posture.

The importance of KYB checks

Now that we understand the meaning of KYB, let’s explore why KYB checks are essential for businesses to not only ensure compliance with AML directives, but also to protect reputation.

1. Risk mitigation

KYB checks help organisations identify and assess potential risks associated with engaging with certain businesses. By verifying the legitimacy and background of their counterparts, businesses can make informed decisions and reduce the likelihood of falling victim to fraudulent activities or financial losses. This proactive approach to risk management is crucial in today’s complex business landscape.

2. Compliance with regulation

Compliance with Anti-Money Laundering (AML) and counter-terrorism financing (CTF) regulations is a critical aspect of operating any business. Most recently, the 5th Anti-Money Laundering Directive put a substantial focus on the importance of ‘Know Your Business’ processes and the 6^th directive increases the financial and personal punishments for non-compliance. Businesses now have a requirement to perform KYB checks ensure that organisations meet their regulatory obligations by thoroughly vetting the businesses they deal with and preventing illicit transactions. Failure to comply with these regulations can lead to severe financial penalties and damage to the organisation’s reputation.

3. Safeguarding reputation

By conducting KYB checks, businesses protect their own reputation and brand image. Engaging with untrustworthy or fraudulent businesses can lead to negative publicity, customer distrust, and long-term damage to the organisation’s reputation. KYB checks help businesses make informed decisions and maintain a strong reputation in the market.

4. Strengthening business relationships

KYB checks promote transparency and trust in business relationships. By demonstrating a commitment to verifying the identity and legitimacy of their partners, organisations foster stronger connections and collaborations. This, in turn, opens doors to new opportunities and enhances the overall success of the business.

Both KYC and KYB checks have always had the same objective – to fully understand the risk that new and ongoing business relationships pose. To understand the risk of a business entity, money laundering reporting officers (MLRO’s) need to know the people responsible for the business, as well as the people who ultimately benefit from that businesses activity, ultimate beneficial owners (UBO’s). They need to know if the business, or the people in the business have been sanctioned, and if so by whom. They need to understand the political network and potential exposure to corruption that individuals running corporations have, and they need any adverse media that surrounds the business.

How FullCircl can help

FullCircl offers a global KYB solution as part of an orchestration platform, which covers data on 365 million entities in 160+ countries. The solution can be integrated via a single API or SaaS based approach to enable businesses to gain real-time access to the information they need on clients and prospects.

The solution includes a full business report which includes information on the following:

• Recommended credit and contract limit to assist contract discussions.
• Ownership and UBO's.
• Full company financials presented in an easily digestible format.
• Payment performance history information to investigate previous partnerships.
• Current and previous directors including share percentages and PEPs & Sanctions.

To learn more about FullCircl’s Know Your Business solutions and how we can help your business stay compliant with Anti-Money Laundering regulations and protect reputation, please contact us today. Simply submit the contact form here, and one of the team will be in touch.

As the world becomes increasingly globalised, businesses must navigate an array of AML PEPs and sanctions regulatory requirements. One such requirement is Anti-Money Laundering (AML) compliance, in particular the 6^th Anti-Money Laundering directive, which involves identifying and verifying customers to prevent money laundering, terrorist financing, and other financial crimes. A key aspect of AML compliance is conducting checks on politically exposed persons (PEPs) and sanctions lists. In this blog, we will provide a guide to AML PEPs and sanctions checks.

What are PEPs?

Politically exposed persons (PEPs) are individuals who hold or have held a prominent public position or function, either domestically or abroad. Examples include heads of state, government officials, judges, and military officers. PEPs are at a higher risk of being involved in money laundering or other financial crimes because of their access to public resources and the potential for corruption. Therefore, it's essential to conduct due diligence on PEPs to ensure that they are not involved in any illegal activities.

It's also important to verify the identity of those associated with PEPs including family members and close associates. Not only are PEPs themselves at a higher risk of being subject or involved in money laundering and other financial crimes but those close to them could also be involved.

What are sanctions?

Sanctions are measures imposed by Governments, international organisations, or other bodies to restrict trade or financial transactions with certain individuals, organisations, or countries. Sanctions may be imposed for several reasons, including terrorism, human rights abuses, or weapons proliferation. Compliance with sanctions is crucial to prevent unwittingly supporting prohibited activities.

Since the conflict began between Russia and Ukraine in 2022, sanctions checking has become even more important for entities to conduct on their customers at the point of onboarding and through re-screening. Not only does sanctions checking form part of compliance requirements for regulated businesses, but it also protects the reputation of an organisation and provides a clearer view on their customer base.

What is a sanctions list?

Sanctions lists are often created to target entities that are believed to be involved in activities such as terrorism, human rights violations, or the development of weapons of mass destruction. The purpose of sanctions lists is to exert pressure on the targeted entities to change their behaviour or to punish them for their actions.

Within FullCircl's AML software, the following global lists apply:

• O.F.A.C (Office of Foreign Assets Control)
• US Treasury Department
• French Asset Freeze List
• HMT (His Majesty’s Treasury Department – UK)
• European Union
• Government of Netherlands National Sanction List Terrorism
• United Nations
• Office of the Superintendent of Financial Institutions
• Ability to include all other global sanctions lists.

Why are PEP and sanctions checks necessary?

PEP and sanctions checks are necessary for AML compliance. Companies must ensure that they do not conduct business with individuals or entities that are on a sanctions list or are considered high-risk PEPs. Failure to conduct these checks can result in hefty fines, reputational damage, and legal consequences.

How to conduct PEP and sanctions checks

There are several ways to conduct PEP and sanctions checks:

1. Manual checks: Companies can conduct manual checks by searching publicly available databases, such as government and international organisation websites. While this method is relatively inexpensive, it can be time-consuming, may not be comprehensive, and there is always the risk of human error in this method.
2. Automated checks: Companies can use automated solutions to conduct PEP and sanctions checks. Automated solutions use artificial intelligence and machine learning to screen databases and flag any matches. This method is more efficient than manual checks and can be integrated into the company’s existing systems.
3. Third-party providers: Companies can also engage third-party providers to conduct PEP and sanctions checks. Third-party providers offer a range of solutions, from manual checks to fully automated systems. Using a third-party provider can be more expensive than conducting checks in-house, but it provides more comprehensive coverage and can also be integrated into existing systems.

How much PEP and sanctions information do I need to obtain?

How much information a business gathers on customers really depends on their risk appetite. FullCircl's Anti-Money Laundering (AML) solution splits these into three levels depending on how in depth the client wants to go within the check. All of these checks can be consumed through a single API integration.

Level 1: Senior Political Figures (SPF) List

• Heads of state and high-ranking government figures around the world.

Level 2: PEP Select List

All the above plus:

• Regional, current, and former PEPs.
• Family members with PEPs.
• Close associates with PEPs.
• FATF (Financial Action Task Force) defined PEP categories.

Level 3: Watchlist (PEP, Sanction & Adverse Media)

All the above plus:

• A much broader spectrum of civil servants, political party officials, senior members of the police force, city mayors, national NGO officials, political pressure and labour group officials.
• Global law enforcement wanted lists.
• Regulatory enforcement actions.
• Global adverse media.
• Global sanctions lists.

What to do if a match is found?

If a match is found during a PEP or sanctions check, companies must conduct further customer due diligence to determine if the individual or entity is indeed on a sanctions list or is a high-risk PEP. If the match is confirmed, companies must take appropriate action, such as freezing assets or terminating the business relationship.

By using orchestration platforms such as FullCircl's offering, businesses can conduct even more in depth checks on their customers which ranges from KYC software, address lookup, fraud prevention, and document verification to confirm a match or in the instance where a more comprehensive view of the customer is required.

PEP and sanctions checks are critical components of AML compliance and the importance of them will only continue to grow. Companies must ensure that they conduct these checks to prevent being involved in financial crimes inadvertently. Conducting checks manually, using automated solutions, or engaging third-party providers are some ways to conduct these checks. If a match is found, companies must conduct further due diligence and take appropriate action. By following these guidelines, companies can ensure that they remain compliant with AML regulations and protect themselves from financial and reputational damage.

If you require more information on how to effectively conduct PEPs and Sanctions, you can contact us here to book a demo.

Voting has now opened for the British Bank Awards 2024. Run by Smart Money People, the British Bank Awards have been celebrating excellence in the banking industry since 2015.

FullCircl is proud to have been voted RegTech Partner of the Year in 2019, 2020 and 2023. So, why do we deserve your vote in 2024?

‍Continuing to drive the RegTech agenda

For us, it’s not a case of ‘won and done’.  We continue to set the pace for innovation in the RegTech market, shaping the future of compliance, risk management and financial crime prevention.  Since last year we’ve:

• Acquired W2 Global Data Solutions to further enhance our expansive datasets and deep subject matter expertise in identity verification, through W2’s global KYC, AML, and anti-fraud services – opening up new consumer verification capabilities alongside our existing corporate entity screening.
• Partnered with nCino to optimise time to funding for SME customers by reducing risk, removing friction and improving enhanced due diligence throughout the customer lifecycle.
• Integrated with ComplyAdvantage to boost our PEPs, sanctions, adverse media and risk screening capabilities, delivering a highly-differentiated and dynamic approach to AML and risk management.

We have a highly-differentiated proposition

Not only are we unique in our ability to deliver both corporate and consumer compliance checks, but we also sit at a unique intersection of the market as a RegTech provider that also delivers a suite of revenue-boosting tools – tackling some of the most critical commercial and regulatory challenges through a single platform.

We help banks and financial service providers profitably identify and acquire, verify and onboard, and retain and grow customers.  Thanks to a range of Smart applications designed to solve specific commercial challenges, we’ve built a vision for the future of banking whereby every stage of the customer lifecycle – from the first engagement, through CDD and onboarding, to in-life customer care and perpertual eKYC – is augmented with the highest quality insight-driven intelligence.

• Identify & acquire: advanced prospecting and sales intelligence
• Verify & onboard: KYC and KYB compliance, Identity Verification, Fraud, AML and credit risk screening
• Retain and grow: perpetual KYC/KYB, ongoing monitoring, customer retention and expansion intelligence

We’ve gone global

We can now identify millions of actionable insights on entities from 160 counties, providing a near real-time record of companies, their officers and shareholders, and importantly the relationships between them – vital in today’s complex and highly-nuanced regulatory environment.

We serve 700+ customers, process over 300 million onboarding and monitoring transactions per month and facilitate the onboarding of 200,000+ customers each year on their behalf.

Can we have your vote?

The British Bank Awards are voted for entirely by you.  It’s a chance to have your say and help us, as we continue to ease the burden on banks and provide cutting-edge solutions to help them grow by connecting the insights they need, when it matters most.

Vote for us here as RegTech Partner of the Year

Warning on Rogue Filings at Companies House

Last week UK Finance, the banking trade association, issued a warning to banks regarding approximately 800 rogue filings relating to 190 companies that had been submitted to Companies House, apparently related to the discharging of erroneous satisfaction of registered charges.

This news comes at the same time as new laws come into force, as part of the Economic Crime and Corporate Transparency Act 2023, giving Companies House greater powers to query, reject, clarify, and remove incorrect information from the register.

Whilst the registrar is working to investigate the matter, and mitigate the risks, it has stated that these incorrect filings – saying a charge has been satisfied – remain valid and enforceable.

A holistic approach to KYB

For FullCircl, issues like this highlight the importance of a holistic approach to KYC/KYB and real-time screening of company data.  In addition to Companies House data (of which we deliver live updates to documents, including mortgages, charges, and debentures), FullCircl provides fast and easy access to comprehensive data on every company in the UK & Ireland – 250 billion data points from more than 40 sources (including credit reference agencies and a range of specialist data partners).

This can assist to not only validate firmographic data from Companies House, but deliver a broader, and deeper view of a company’s health. FullCircl users are also able to track their clients and receive notifications when a mortgage is satisfied, prompting further review if necessary.

FullCircl customers can rest assured that we are monitoring the situation to ensure that accurate information is provided via our suppliers. Get in touch with your account manager if you have any questions or concerns about the Companies House rogue filings.

‍

On 31^st January 2024 we held an elite gathering of some of the UK's most influential insurance broking leaders. The setting for this auspicious event was the iconic NED, one of London's most exclusive member clubs.

We brought together experts from across the industry, from large brokers to independent regional firms, to talk about their biggest challenges - from onboarding speed and underwriting accuracy, to underinsurance, risk and fraud reduction, and meeting compliance duties. Not only were they treated to a slap-up lunch, but they also heard from five of the most innovative thinkers in the broking industry.

Kicking things off was our very own Andrew Yates.

A trifecta of digital broking excellence

Andrew talked about how FullCircl + Acturis + BIBA is a trifecta of success - taking the knowledge, guidance, and experience of BIBA, quantifying that into rules and data insights within FullCircl, and then surfacing them to generate meaningful opportunities for growth within Acturis.

The results being:

• More accurate underwriting submissions, and therefore better premiums, terms and outcomes for clients.
• Huge time savings and reduction in manual effort. Leaving brokers free to focus on what they do best - providing advice and service that supports and protects clients.
• Better relationships for both clients and underwriters.
• Improved compliance with the Consumer Duty - connecting insights and actions to deliver positive outcomes that protect clients from financial harm.

This was a great segue into the talk by Swati Chopra, Chief Information and Technology Officer at Partners&.

One version of the truth

Swati talked about why poor-quality data is the enemy of broking success - causing financial loss, operational efficiencies and increased workloads, compliance issues, and difficulties with analysis and reporting.

A key collaborator and the first broker to go live with the FullCircl SmartBroker + Acturis integration, Swati explained how having a single version of the truth, with high-quality reliable data and customer lifecycle intelligence saved them hundreds of hours in just a few months. She highlighted benefits including:

• The ability to efficiently identify and win new customers.
• Performing better due diligence and accelerating onboarding.
• Improved in-life monitoring for better renewal rates.

Responding to industry shifts

A real highlight of the event was hearing from Acturis CEO Tony Goddard. His insights into the current and future trends of the industry were truly enlightening.

Speaking about his experience of the event, Tony said "The event was a great opportunity to network and discuss the real business value of the Acturis + FullCircl integration with our customers."

Tony highlighted how FullCircl + Acturis, two of the most recognisable technology partners within the insurance sector are helping brokers forge a new path in the digital era by revolutionising growth & client retention strategies. Formed in response to industry shifts, and built in collaboration with brokers, the partnership is helping brokers Identify & Acquire, Verify & Onboard, and Retain & Grow clients and prospects - ultimately connecting the insights they need, when it matters most.

Managing risk for growth and economic security

The luncheon was held just days after BIBA launched its 2024 manifesto 'Managing risk for growth and economic security'. We were therefore delighted that BIBA CEO Graeme Trudgill was able to join us.

As well as discussing his first few months as CEO, including a day one call from Michael Gove on the controversial subject of broker commission, Graeme talked about BIBA's recent research indicating that insurance broker regulation, particularly the Consumer Duty, has placed a disproportionate burden on the industry.

He also talked about tools such as SmartBroker are highly effective when it comes to assisting brokers to drive increased efficiency and reduced regulatory costs, which in turns creates more opportunities for growth.

Finally, we heard from David Sparkes, Regulation Director at BIBA.

A war cry

David ended the lunch with call to arms for brokers to push back when it comes to disproportionate regulatory demands. Explaining why, in its manifesto, BIBA has called for effective scrutiny of the FCA's growth and competitiveness objectives, as well as the scope of the Consumer Duty, he reaffirmed the themes of the day, and why connecting insights is vital if brokers are to continue to grow and flourish in the UK.

It's a game changer

If you'd like to learn more about FullCircl + Acturis + BIBA, then why not book a personal demo? Experience SmartBroker's capabilities first hand and explore how we can help you identify & acquire the right customers, verify & onboard them faster (while also assisting with Consumer Duty requirements), and retain and grow your existing portfolio whilst maximising revenue.

Want to join our next lunch?

Our invitation only lunch series is very popular but we're always keen to welcome new faces. If you're interested in joining the discussion, get in touch with us today.